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The policy states that for users under 13, persistent identifiers such as IP addresses and device identifiers are collected and used only for the six enumerated internal operations purposes, and that Roblox implements technical and contractual measures to enforce this restriction.
This analysis describes what Roblox's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes COPPA-compliant limitations on persistent identifier use for users under 13, with the policy asserting that technical and contractual safeguards are in place to prevent use beyond the enumerated purposes, including a restriction to contextual advertising only (no personalized advertising) for this age group.
Under this clause, Roblox limits data collection for users under 13 to persistent identifiers used only for the six listed internal operations, with contextual advertising permitted but personalized advertising prohibited. The policy states that technical and contractual measures enforce these restrictions on service providers who process this data.
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"Roblox collects persistent identifiers and the information we ask you for when you sign up for the following internal operations: Maintaining or analyzing the functioning of Roblox; Performing network communications; Authenticating users of, or personalizing the content on, Roblox; Serving contextual advertising, including capping the frequency of ads; Protecting the security or integrity of Roblox; Ensuring legal or regulatory compliance. Roblox implements technical, contractual, and other measures to ensure that persistent identifiers are not used for purposes other than those listed above.Excerpt from Roblox's Privacy Policy
1. REGULATORY LANDSCAPE: This provision directly implements COPPA's operator and support for internal operations framework, as defined in 16 CFR Part 312. The FTC is the primary enforcement authority. The enumerated purposes align with the COPPA Rule's definition of 'support for the internal operations' of a website or online service. Serving contextual advertising while prohibiting personalized advertising for users under 13 is consistent with COPPA's restrictions on behavioral advertising targeting children. 2. GOVERNANCE EXPOSURE: Medium. The adequacy of Roblox's technical and contractual measures to prevent persistent identifier misuse by service providers is a factual compliance question that cannot be assessed from policy language alone. FTC enforcement actions in the children's privacy space have focused on gaps between stated policy commitments and actual technical implementation. 3. JURISDICTION FLAGS: COPPA applies to US-based operators and to operators targeting US children regardless of where the operator is based. The EU's GDPR and UK GDPR impose additional restrictions on processing children's data, including requirements for age-appropriate design. Some US states (including California under the Age-Appropriate Design Code Act, to the extent it remains in effect) impose additional child-specific data restrictions. 4. CONTRACT AND VENDOR IMPLICATIONS: Service provider agreements must include contractual restrictions limiting persistent identifier use to the enumerated COPPA internal operations purposes. Procurement teams should assess whether vendor DPAs and service agreements specifically enumerate these restrictions and include audit rights to verify compliance. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should verify through technical audit that persistent identifiers from users under 13 are tagged and segregated in systems in a manner that technically enforces the purpose restrictions stated in the policy, confirm that all service providers with access to this data have signed agreements that specifically prohibit use beyond internal operations, and assess whether data retention periods for persistent identifiers from users under 13 comply with COPPA's requirement to retain data only as long as reasonably necessary.
This provision establishes COPPA-compliant limitations on persistent identifier use for users under 13, with the policy asserting that technical and contractual safeguards are in place to prevent use beyond the enumerated purposes, including a restriction to contextual advertising only (no personalized advertising) for this age group.
Under this clause, Roblox limits data collection for users under 13 to persistent identifiers used only for the six listed internal operations, with contextual advertising permitted but personalized advertising prohibited. The policy states that technical and contractual measures enforce these restrictions on service providers who process this data.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.